ML042610147
| ML042610147 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/05/2004 |
| From: | FirstEnergy Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| FOIA/PA-2004-0277 CR-03-08460 | |
| Download: ML042610147 (18) | |
Text
JUL-08-2004 15:50 NRC BEAVER VALLEY P. 05 NOP-LP.2001 01 Beaver Valley CONDITION REPORT lCR Numnber TITLE: INADEQUATE FIRE PROTECTION SAFE SHUTDOWN ANALYSIS OF HIGH-LOW PRESSURE INTERFACE DISCOVERY DATE I TIME I EVENT DATE TIME l SYSTEM/ ASSET*
B/6/2 0 03 LN/A 8/6/2003 N/A J N/A 2RCS-PCV455D, 2RCS-PCV4S6 EQUIPMENT DESCRIPTION Pressurtzer Power Opetoted Rellef Valves DESCRIPTION OF CONDITION and PROBABLE CAUSE (if known) Summarize any atachments. Identlty what, when, where, why, how.
0 Fire protection safe shutdown method as reflected in Operating Manual Procedure 20M56B.3.B.3, R Attachment 1, Step 22, for a fire in the BVPS-2 west cable vault CV-1, is not adequate to defeat I potential fire induced spurious operation of the PORV. This conclusion is based on circuit analysis guidance provided in NUREG 0800, Standard Review Plan 9.5.1, Fire Protection Program, and I UFSAR Section 9.5A.1.2.1.6.
N This procedure step deenergizes the PORVs by opening breakers at the d-c distribution panel. This A is inadequate because the deenergized circuit is routed in cable trays with other energized circuits in T the fire area. A cable-to-cable hot short could re-energize the circuit.
I o The manual action identified for the Pressurizer PORV for fire area CV-1 (20M56B.3.B.S, N Attachment 1, Step 22) is as follows:
"If pressurizer instrumentation indicates that a PORV is open, the PORV can be Closed by de-energizing the associated power source as follows:
[PNL-DC2-02] Bkr 8-1, supply to 12RiCS'PCV455C), PZR Power Relief (Control Bldg - 707'. MCC Room).
[PNL-DC2-03] Bkr 8-2, supply to [2RCS*PCV455D], PZR Power Relief (Control Bldg - 707', SDP Room).
[PNL-DC2-031 8kr 8-1, supply to [2RCS'PCV456], PZR Power Relief (Control Bldg - 707', SDP Room)."
The first part of the above step (deenergizing 2RCS'PCV455C) is not essential because the circuits are enclosed in fire wrap. However, 2FCS'PCV455D and 2RCS*PCV456 are subject to spurious actuation by fire in area CV-1.
SSER5, page 9-9 states that "Reactor coolant inventory is ensured by maintaining reactor coolant pump seal injection and by isolating possible locations of inventory loss such as PORVs, RHR suction lines, letdown line and reactor head vents."
UFSAR 9.5A1.2.1.6 Connection to Control Circuits/Spurious Operation states:
'The safe shutdown capability should not be adversely affected by a fire in any plant area which results in spurious actuation of the redundant valves in any one high-low pressure interface line."
Although the original design aDpears to be based upon the low likelihood of the multiple shorts which Would be required to cause a spurious PORV actuation in an ungrounded UC circuit. this approach is not consistent with staff guidance for high-low pressure interface valves.
The following excerpt from GL 86-10 is provided to illustrate the staff position on Hi/Lo Pressure interfaces:
'5.3.1 Circuit Failure Modes QUESTION What circuit failure modes must be considered in identifying circuits associated by spurious actuation?
RESPONSE
Page 1 of 4 A0
J U"-VM-&WWJ'- 1 1 NM-L =HVtK VHLLtY P.06 NOP-LP-2001-01 Beaver Valley CO ND ITI ON RE PORT l Nube TITLE: INADEQUATE FIRE PROTECTION SAFE SHUTDOWN ANALYSIS OF HIGH.LOW PRESSURE INTERFACE Sections III.G.2 and111.L.7 of Appendix R define the circuit failure modes as hot shorts, open circuits, and shorts to ground. For consideration of spurious actuations, all possible functional failure states must be evaluated, that is,the component could be energized or de-energized by one or more of the above failure modes. Therefore, valves could fail open or closed; pumps could fail running or not running; electrical distribution breakers could fail open or closed. For three phase AC circuits, the probability of getting a hot short on all three phases in the proper sequence to cause spurious operation ot a motor is considered sufficiently low as to not require evaluation except for any cases i lg HiLo ressure Interfaces. For ungrounded DC circuits, if it can be shown that only two 'ot snortsot the proper polarity without grounding could cause spurious operation, no further evaluation is necessary except for any cases involving Hi/Lo pressure interfaces.'
The above statement is interpreted to mean that for high-low pressure interface valves, multiple hot shorts must be postulated due to a fire. Therefore a short circuit from the positive polarity of an energized (aggressor) circuit to the positive of the victim circuit, and from the negative to negative, must be postulated.
NEI Further interpretation and clarification of this requirement is contained in recently issued document NEI 00-01, Section 3.5.2.3, Circuit Failures Due to a Hot Short. as follows:
"A hot short between any external energized source such as an energized conductor from another cable and a de-energized conductor may also cause a spurious actuation of equipment. This is called a cable-to-cable hot short or an external hot short."
The control circuit for 2RCS*PCV456 includes, among other cables, 2RCSNOC601. This cable contains conductors 01 and N1, which, if connected to an external source of 125 VDC would result in the spurious actuation of 2RCS*PCV456. (Reference 10080-E-1l1L, Sheet 1). This cable is routed in 11 cable trays, 3 conduits, and reactor containment penetration junction box in fire area CV-1, therefore there is a high probability that it is routed with other energized circuits creating a potential for a cable to cable hot short.
The control circuit for 2RCS'PCV455D includes, among other cables, 2RCSNOC606. This cable contains conductors 01 and N1, which, if connected to an external source of 125 VDC would result in the spurious actuation of 2RCS'PCV455D. (Reference 10080-E-1 1L. Sheet 3). This cable is routed in 6 cable trays, 1 conduit and reactor containment penetration junction box in fire area CV-1; therefore there is a high probability that it is routed with other energized circuits creating a potential for a cable to cable hot short.
The redundant isolation valves, i.e., the PORV block valves 2RCS-MOV536 and 537 also have control circuits in the same fire area. In addition the valves are normally open and fail as-is on the loss of Train A (orange) emergency power. A fire in CV-1 is postulated to result in the loss of Train A, with Train B being the protected train in this fire area.
The two cables mentioned above are examples of cables potentially affected in fire area CV-1. It is likely that hot shorts on other cables for these PORVs in the same fire area would also have the potential to cause spurious actuation.
The above condition was identified during the review of CA03-07437-1Q which st tes "Review manual action for spurious oneralion of PORV with a fire in Unit 2 fire area CV-1. Confirm that the circuit analysis and m anual action analysis methodoloy for hih-o inerface valves as defined in FPSSR Appendix A4 an ppendix .5A."
Probable cause of this condition was inadequate spurious signal analysis during the original circuit analysis performed in 1987.
Page 2 of 4
JUL-06-2004 15:50 N4RC BEAVfER VALLEY P. 07 NOP-LP-200101 Beaver Valley TITLE: INADEQUATE FIRE PROTECTION SAFE SHUTDOWN ANALYSIS OF HIGH-LOW PRESSURE INTERFACE Extent of Condition Review Fire Area RC-1, Reactor Containment A deviation is documented in FPSSR Section 3.31, under Section 3.2, Spurious Actuations. This deviation states that "the multiconductor cables are subject to hot shorts, internal to the cable only."
This statement is inconsistent with current guidance, which requires that cable-to-cable hot shorts also be considered. Control circuits in containment (e.g. 2RCSNPC602 for PCV455C, 2RCSNOC607 for PCV455D, 2RCSNOC602 for PCV456) are routed in cable trays in containment (not dedicated conduit) and are therefore likely to be in raceways with other energized circuits.
Fire Areas CB-1, CB-2, CB-3, CB-6. CT-1, CV-1, SB-1 contain similar manual actions to deenergize the POFIV circuits. It is likely that the circuits deenergized in this manner are routed with other energized circuits in these fire areas and are therefore subject to spurious actuation by cable to cable hot shorts.
BVPS Unit 1 Applicability This specific condition is not applicable to Unit 1 because Unit 1 has a different compliance strategy for the PORVs. The PORV and associated block valves are powered by opposite trains and thus the motor operated isolation valve is routed through the opposite cable vault than the PORV cables.
Isolation switches were installed in each cable vault to isolate short circuits in other areas outside the cable vaults. An exemption was documented for separation inside containment. Chapter 8 of the BVPS-1 Appendix R Report provides further details.
Note - Engineering has investigated other nuclear plants for comparison. North Anna performed a modification as a result of their 1984 Appendix R reanalysis by which the PORV circuits in Containment were rerouted in dedicated conduit, and isolation switches were installed in the cable vaults. This was documented in an Appendix R exemption.
Compensatory Action Recommended Engineering recommends an hourly roving fire watch patrol be established for the affected fire areas at Unit 2 as compensatory measures, with the exception of the Main Control Room and the Reactor Containment area, until the condition is fully evaluated and resolved. The Main Control Room is continuously manned and does not require an hourly fire watch patrol. The Reactor Containment area is not accessible during normal power operations and, as such, compensatory measures for this area will include a once-per-shift verification of remote instrumentation by operations personnel to confirm that there are no abnormal conditions or indications for this area.
SPECIAL INSTRUCTION - CR CAN BE DOWNGRADED TO CA PROVIDED DESIGN ENGINEERING PROVIDES A SIGNED DOCUMENT THAT PROVES THIS WAS NOT A SIGNIFICANT DEGRADATION, EXTENT OF CONDITION ALSO REQUIRED. THIS ALSO REQUIRES WITHDRAWAL OF 10CFR50.72 SUBMITTAL Page 3 of 4
.JULO3VID' w4 4
1~*Vc NXU bl.HVER VRLLEY P. 0 NOP-LP-2001-01 Beaver Valley CONDITION REPORT lR Number6 TITLE: INADEQUATE FIRE PROTECTION SAFE SHUTDOWN ANALYSIS OF HIGH-LOW PRESSURE INTERFACE IMMEDIATE ACTIONS TAKEN I SUPV COMMENTS (Discuss CORRECTIVE ACTIONS completed, basis for closure.)
Discussed with D. Held. Alerted Integrated Procedures group of potential need for procedure changes. Recommend downgrade to CA if not reportable.
aUUTiu ORGANIZATIONUSEONLY l IDENTIFIED3BY(Chock one. O vReveed A1T;ACHMENTS Quality Org. Initiated Cn Ye3 IndivIdu3aWork Group C Internal Oversight i Quality Org. Follow-up O Yes El No l SupervisionlhManagerrent External Oversight Yes O No ORIINATOR ORGANIZATION DATE SUPERVISOR DATE P EXT.
KAHL, H 0030 l 816/2003 MANOLERAS, M I86/2003 773S SRO EQUIPMENT :EVALUATION lORG. IMMEDIATE ORG. MODE REVIEW OPERABLE !REIUIRED NOTIFIED INVESTIGATON REQUIRED NOTIFIED CHANGE Y
eYS NO I Yea[D No NtA Pi Yes EONo DYes 0 40 _ Yes EJ nJ MODE I ASSOCIATED TECH SPEC NUMBER(S) ASSOCIATED LCO ACTION STATEMENT(S)
A R N 213UZ7 **
- T _
DECLAREDINOPERABLE rREPORTABLE? OneHour NIA J PL LICABLE UNIT(S) 0 (Date I Time) Z9 Yes lJ No P N/A Elght Hour IOCFR50.72(b)(3)Xii)(B) O UI 0 U2 0 Bolh E .. ...
Eval Required .
R COMMENTS A Based on the information provided, 10.50.72 Non-Emergency 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Notification will be required.
T Additionally, Security has been notified at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> to establish a once per hour Fire Tour for CB-I 1. Control Bldg Instrument/Relay Room 707'el., CB-2, Control Bldg Cable Spreading 725'el., CB-6 O W. Comm. Room 707'el., CT-1 Cable Tunnel 712'el., CV-1 W. Cable Vault 735 and SB-1 AE N SWGR 730"el. The Containment Building Temperature will be monitored 1/hour, Containment Fire S Detection is available, and the Control Room is continuously manned. All affected equipment remains Operable and Available.
CUrrent. Mode-` Unit I Power Level- Unlt 1 Current Mode - Unit 21 Power Level - Unit 2 N/A N/A 1 DO1%
SRO - UtIlT i SRO - UNIT 2 DATE NIA Witter, J 6/612003 CATEGORY I EVAL lASSIGNED ORGANIZATON I DUE DATE ,n REPORTABLE?
CF 0030 I 9120/2003 ij Yes No Ca LER NO.
CRPA TREND CODES CompTypeIID Cause uREPORTABIUTREVIEWER I Process /ActivitylCause Codols) (If CauseTorW) Org A Fedin R SUPV LP6 1650 B04 0030 o .,. .. -
.~ IR DATE MRS _ _ 09/05/03 INVESTIGATION OPTIONS CLOSED BY DATE MamnLRuloC DOE Evauuioon I Page 4 of 4
JUL-Un-eIJ04 ID;Zi NXL HhRHV\H VRLLEY P. 09 Atnehment CONDITION REPORT CR Number 03-08460 REPORTABILITY DETERMINATION:
Based upon the information supplied in the NRC notification # 40049 issued on August 6 and updated on August 7, 2003, this was reported as an unanalyzed condition that significantly degraded plant safety since the failure to assure the PORVs remain in the closed position could result in the failure to meet the fire protection safe shutdown criteria. This was reported pursuant to 10 CFR 50.72(b)(3)(ii). By the same reasoning, this is also reportable pursuant to 10 CFR 50.73(a)(2)(ii). Thus, a LER must be issued within 60 days of the date of this CR. The LER must be issued by Friday, October 3, 2003.
' eUPDATE '*-
This event was initially reported pursuant to 10 CFR 50.72(b)(3)(ii)(B) as a unanalyzed condition that significantly degrades plant safety because it was unanalyzed and the consequences were unknown.
Therefore, it was reported as a conservative reporting conclusion.
The original BVPS Unit 2 Fire Protection Program required that the plant's safe shutdown capability would not be adversely affected by a fire in any plant area which results in spurious actuation of the redundant valves in any one high-low pressure interface line (See UFSAR page 9.5A-7). This included the Pressurizer PORVs. The BV2 Fire Protection Program did acknowledge that the PORVs were 01t'-m4 subject to hot shorts, internal to the cable only, that could result in a spurious actuation of the PORV (See UFSAR page 9.5A-137). Thus, a specific deviation was obtained for spurious actution of PORVs.
DemwA~ The UFSAR states 'To mitigate the consequence of a spurious actuation that would result in an uncontrolled depressurization, the circuit breaker for the 2RCS*PCV455C,D and 456 will be opened on
+- the first indication of a fire in RC-1. In addition, circuit breakers for computer signal isolators will be opened, to deenergize all conductors in the cables." Thus, these compensatory measures identified in the UFSAR effectively eliminates the hot (internal to the cable) short, and causes the PORVs to fail closed, and a stuck-open PORV did not have to be analyzed. This also includes not analyzing a stuck-open PORV due to a cable-to-cable or external hot short. As noted in the CR, based on recent industry guidance (NEI 00-01, Section 3.5.2.3) that a cable-to-cable hot short may also cause spurious actuation of equipment, the previous compensatory measures (to manually de-eneralze the PORVs and block valves) could now not be effective since the controls could be energized by a lire even thouoqh the power was removed remotely! and aMBV muldle soursis opened. Thus, the 50.72 report was made on A-ugust 6, 200-3.~
Information supplied via Federal Register Vol 68, No. 159 (page 49532) on August 18. 2003 regarding hot shorts states "Recent testing strongly suggests that fire-induced hot shorts will likely self-mitigate (e.g., short to ground) after some limited period of time. Available data remains sparse, but there are no known reports of a fire-induced hot short that lasted more than 20 minutes. This is of particular importance to devices such as air-operated valves (AOVs) or pressure-operated relief valves (PORVs) which return to their de-energized position upon mitigation of a hot short cable failure. Pending further f*M research, inspectors should defer the consideration of such faults if they can verify that a spurious operation of up to 20 minutes duration will not compromise the ability of the plant to achieve hot shutdown."
With recognition of this new information, the postulated event for spurious PORV opening due to an external cable-to-cable hot short from a fire was analyzed. The Fire Protection Program requires that the plant's safe shutdown capability be maintained for any fire event. Calculation 1080-DMC-0820 was completed on September 4, 2003. The calculation assumed that a (single) PORV and Its associated block valve both spuriously open, and assumed credible bounding assumptions for this postulated event (e.g., no Initial charging/HHSI/LHSI flow with one HHSI pump returned at 33 minutes, a RCP seal leak which progresses to a seal LOCA. etc.). The calculation results show that initially the RCS water inventory is reduced (until the HHSI pump is returned), but the reactor core Is not uncovered, and hence Page I of 2
JUL-06-2004 15:51 N4RC BEAVtER VJALLEY P. 10 Attachment CONDITION REPORT lCR Number 03-08460 remains undamaged. Following the HHSl pump return, plant condition remain either relatively stable or ok start to improve (e.g., reactor vessel water level slowly rising). Although containment cooling is not available for the bounding fire scenario, the hot short scenario is assumed for only 20 minutes, which is not sufficient time to overpressurize the containment. Thus, the radiation dose to the public and workers is bounded by the other UFSAR traditional DBA analyzed events (i.e., LOCA and main steam line break). Therefore, since the reactor core does not experience an unrecoverable plant condition and the radiological conditions remained bounded by analyzed DBAs, the plant's safe shutdown capability for a neQ fire event is maintained. Although the now-credible spurious opening of a PORV is a deviation from the current Fire Protection Program criteria (which will be addressed separately by this CR's corrective actions), the results of the spurious PORV opening does not adversely impact the plant's safe shutdown TIeRI Fibm~ capability and hence is not a significant degradation of plant safety.
Therefore this condition is not reportable pursuant to either 10 CFR 50.72(b)(3)(ii)(B) nor 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly degraded plant safety.
A retraction of the prior 50.72 notification will be pursued.
Prepared by Ron Fedin and John Maracek, 9/5/2003 Page 2 of 2
JUL-06-2004 15:51 N4RC BEAVER VALLEY P. l1 CORRECTIVE ACTION CR Number:
NOP-LP-2001 -05 03-08460 CRCategory: ActlonType: Schedule Type: CA Number:
CF (Z) Rollover (A) Normal Work Management 1 Corrective Action Type: Cause Code! Rasp Org:
( OT) Other Actlon (NA) Not a Deficiency 0030 R
Description:
I Condition Report 03-08501 is being categorized as CC and being rolled over to Condition Report 03-G 08460. Please ensure that all issues specific to Condition Report 03-08501 are addressed in the I response/corrective actions to Condition Report 03-08460.
N A
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R Completed By. Organization: Date: Phone: Attachments:
ROLLOVER. 009 8/1112003 0000 C1 Yes e No If a Refueling Outage Is required, Other Tracking # Corrective Action Due Date:
ACC- Enter the Reluellng Outage number: IN/A l 915/03 EPT Approval: (Enter Name and Sign) Section: Date:
ROLLOVER. 0030 8/111/2003 QUAL Quality Organization Approval: Date;
-ITY I Response:
M The condition identified in CR 03-08501 is identical. The second condition report was written to P identify other fire areas requiring compensatory action in addition to the areas identified in 03-08460.
Cause isthe same, as the manual actions for all the fire areas were developed in the same spurious E signal analysis. Corrective actions for all 13 fire areas are being addressed in ECP 03-0431.
E M
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T I Corrective Action implementation Date: 8/25/03 N .£ Signature indicates Corrective Action complete:
G Completed By: KAHL. H Date: 8/25/2003
,d Signature indIcates verification tor SCAO CRs:
O Verified By: Date:
R ,j Enter Name and Sign:
Implementing Organization Approval: MANOLERAS, M Data: 8/29/2003 o v Comments:
UE A R L I IF TI YE R Approval: Date:
Page 1 of B
JUL-Ub-dWU4 lt:l N4RCCl BEAVER VALLEY P. 12 CORRECTIVE ACTION CR Number:
NOP-LP-2001-05 03-08460 CR Category: Action Type: Schedule Typo: CA Number:
CF I (V) Other (A) Normal Work Management 2 Corrective Action Type: Cause Code: Rosp Org:
O (OT) Other Action ( NA) Not a Deficiency 0062 R
Description:
I The issue described in CR 03-08460 is reportable pursuant to 10 CFR 50.73(a)(2)(ii). Thus, a LER G must be issued within 60 days of the date of this CR. The LER must be issued by Friday, October 3, N 2003.
N A
T 0
R Completed By: Organizatlon: Date: Phone: Attachments:
FEDIN, R 0060 8/16/2003 5221 0 Yes 3 No I a Refueling Outage Is required. Other Tracking # Corrective Action Due Date:
ACC- Enter the Refueling Outage number: NrA 1013/03 EPT Approval: (Enter Name and Sign) Section. Date:
SEPELAK. B 0050 8/1B/2003 DUAL Quality Organization Approval: Date:
- ITY i Response:
hl It was subsequently determined that this event is not reportable (See revised reportability P determination description). The prior 50.72 notification (# 40049) was retracted on 9/1812003.
£ Therefore, no LER will need to be issued on this CR.
E M
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T I Corrective Action Implementation Date: 9/18/03 N e. Signature Indicates Corrective Action complete:
G Completed By: FEDIN, R Date: 9/18/2003
.d Signature indicates verification for SCAO CRm:
O Verified By: Datc:
R ,J Enter Name and Sign:
M ImplemeriIng Organization Approval: SEPELAK. B Date: 9/1912003 tJ Comments:
UE AR LI IIF T I YE R Approval: Date:
Page 2 of e
JUL-06-2004 15:51 NRC BEAVIER VALLEY P. 13 CORRECTIVE ACTION CR Number:
NOP-LP-2001 -05 03-08460 CR Category. Action Type: Schedule Type: CA Number:
CF (E) Modifcations Implementation (C Refuel Outage Required for Implamenta 3 Corrective Action Type: Cause Code: Resp Org:
O (RA) Remodlal Action (B04) Design analysis 0030 R Descrlptlon:
I Issue ECP 03-0431 to provide capability to isolate PORV cable-to-cable fire Induced hot shorts.
G N
A T
0 R
Completed By: Organization: Date: Phons: Attachments:
KAHL. H 0030 8/25/2003 5064 U7Yes E No If a Refueling Outage is required, Other Trackng J Corrective Action Due Date:
ACC, Enter the Refueling Outage number: N/A N/A 10/1504 EPT Approval: (Enter Name and Sign) SectIon: Date:
MANOLERAS, M 0030 9/5/2003 OUAL QualIty OrganizatIon Approval: Date:
-ITY I Response:
M The funding for this ECP was not approved. A deviation request will be submitted to request NRC P approval to retain the existing configuration, as per Corrective Action 4, and the BCO has been L revised accordingly via BCO 2-03-003 Rev. 1 approved 9124/03.
E M
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T I Corrective Action Implementation Date: 9124/03 N ;3 Signature indicates Corroctliv ActIon complete:
G Completed By. KAHL, H Date: 9/24/2003 j Signature Indicates verification for SCAD CRs:
O VerIfIed By: Date:
R ;3 Enter Name and Sign:
_ Implementing OrganIzatlon Approval: Manoleras, M Date: 10/7/2003 AR Comments:
UE AR LI IF TI YE R Approval: Date:
Page 3 of 8
JUL-06-2004 15:51 NRC BEAVJER VALLEY P.14 CORRECTIVE ACTION CRNumber:
NOP-LP-2001 -a 03-08460 CR Category: Action Type: Schedule Type: CA Number:
CF I (U) Othor Evaluation (A) Normal Work Management 4 Corrective Action Type: cause Code: Hesp Org:
O (CM) Compensatory Measure (NA ) Not a Deficiency 0065 R
Description:
I The potential for spurious opening of a PORV is a deviation from the current Fire Protection G Program criteria and needs to be addressed. A "Deviation Request" will need to be submitted to NRC for review and subsequent approval by the NRC.
N Reg Affairs will provide the deviation request submittal to NRC, based on the technical justification T provided by Engineering (Ref. CA 03-08460-05).
O 0
R Completed By: Organization: Datoe Phone: Atachments:
MARACEK. J 0060 9/8/2003 5232 1 Yes RJ No li a Refueling Outage Is required. Other Tracking # Corrective Action Due Date:
ACC- Enter the Refueling Outage number: N/A NIA 2/14104 EPT Approval: (Enter Name and Sign) Section: Date:
IMARACEK, J 0060 9/12/2003 QUAL Quality Organization Approval: Date:
-ITY I I Response:
M A "Deviation Request" letter was approved for submittal to the NRC on 2113/04.
P l
Reference:
Letter From L. William Pearce to U.S. NRC. "Proprosed Revision to the Previously L Approved Deviation from Branch Technical Position (BTP) CMEB 9.5-1,* Letter Number L-04-01 9, E February 13. 2004.
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I Corrective Action implementation Date: 2/13/04 N a Signature indicates Corrective Action complete:
G Completed By. MCMULLEN. K Date: 2113/2004 V signature indicates verification for SCAQ CRs:
O Verified By: Date:
R U Enter Name and Sign:
Implementing Organization Approval: Freeland, L Date: 2/132004 oV Comments:
UE AR LI IF TI YE R Approval: Date:
Page 4 of 8
JUL-06-2004 15:51 N4RC BEAVER VALLEY P. 15 CORRECTIVE ACTION CR Number; NOP-LP-2001-05 03-08460 CR Category: Action Type: Schedule Type: CA Number:
CF (U) Other Evaluation (A) Normal Work Management 5 Corrective Action Type: Cause Code: Resp Org:
((CM) CompenSatory Measure (1H03 ) Change mgmL 0030 R
Description:
I Engineering to provide the technical justification to support the deviation request submittal to the G NRC for the the potential hot short, spurious opening of a PORV fire protection issue which is a I deviation from the current Fire Protection Program criteria.
N A The deviation request will be a proposed revision to a previously approved deviation from BTP T CMEB 9.5-1 Section C.5.b Safe Shutdown Circuitry identified presently in our UFSAR Section 9.5A T under the "Spurious Actuations' section (page 9.5A-1 37) which discusses the Przr. POI\rs.
R Completed By: Organizatlon: Date: Phone: Attachments:
MARACEK. J 0080 Q9//2003 5232 0 Yes El No It a Refueling Outage Is required. Other Tracking # Corrective Action Due Date:
ACC- Enter the Refueling Outage number: N.A N/A 10/22/03 EPT Approval: (Enter Name and Sign) Section, Date:
LUSERT, R 0030 9111/2003 QUALI uality Organization Approval: Date:
-ITY I Response:
M Technical Justification:
NUREG 0800 BTP 9.5-1 and UFSAR require a train of safe shutdown equipment to be protected L from the effects of a fire. Generic Letter 86-10 indicates that multiple hot shorts must be postulated L for Hi/Lo pressure interface valves. Protection was not provided for PORV circuits to the extent E required by these documents.
M E The failure mechanism for this non-conformance would occur if a fire event caused an energized N cable to short to the PORV control circuits (positive to positive, negative to negative), while T simultaneously damaging the PORV block valve circuits to cause them to fail open or to fail in place.
N The important to safety function is maintaining the reactor coolant pressure boundary to achieve G safe shutdown following a fire in any plant area. Open PORVs result in a loss of reactor coolant inventory (vapor space LOCA) which potentially could impair the post-fire safe shutdown capability 0 The event that the safety function provides protection against is a fire induced LOCA.
R G BV Design Analysis Calculation No. 10080-DMC-0820 has determined that no core damage would occur in the event of a spurious PORV opening under credible fire protection scenarios.
The analysis (See Note 1 & 2 below) of the non-conforming condition and the potential consequences has determined that the results of a fire induced spurious PORV opening does not adversely impact the plant's safe shutdown capability. Hence, it is not a significant degradation of plant safety. Although the non-conforming condition still exists, the condition and the potential consequences have now been further analyzed (See Note 1 below) and it has been determined that the condition does not adversely impact the plant's safe shutdown capability and hence is not a significant degradation of plant safety.
Page 5of8
JUL-Wb-dW4 1 Nt,& BttHVH-V L VHLLLY P. 16 CORRECTIVE ACTION CR Number 03-08460 NOP-LP-2001-05 Note l: Calculation No. 10080-DMC-0820 was completed 914/03. The calculation assumed that a single PORV and its associated block valve both spuriously open, and assumed credible bounding assumptions for this postulated event. The results of the calculation state in part; "...the success criteria for this sequence is satisfied; i.e., no core uncovery occurred, therefore the core is not damaged."
The calculation results show that initially the RCS water inventory is reduced (until the HHSI pump is returned), but the reactor core is not uncovered, and hence remains undamaged. Following the HHSI pump return, plant condition remains either relatively stable or starts to improve (e.g., reactor vessel water level slowly rising). Although containment cooling is not available for the bounding fire scenario, the hot short scenario is assumed for only 20 minutes (See Note 2 below), which is not sufficient time lo overpressurize the containment. Thus, the radiation dose to the public and workers is bounded by the other UFSAR traditional DBA analyzed events (e.g., LOCA and main steam line break). Therefore, since the reactor core does not experience an unrecoverable plant condition and the radiological conditions remained bounded by analyzed DBAs, the plant's safe shutdown capability for a fire event is maintained.
Note 2: Information supplied via Federal Register Vol 68, No. 159 (page 49532) on August 18, 2003 regarding hot shorts states: "Recent testing strongly suggests that fire-induced hot shorts will likely self-mitigate (e.g., short to ground) after some limited period of time. Available data remains sparse, but there are no known reports of a fire-induced hot short that lasted more than 20 minutes. This is of particular importance to devices such as air-operated valves (AOVs) or pressure-operated relief valves (PORVs) which return to their de-energized position upon mitigation of a hot short cable failure. Pending further research, inspectors should defer the consideration of such faults if they can verify that a spurious operation of up to 20 minutes duration will not compromise the ability of the plant to achieve hot shutdown." This same industry guidance nofes that Inter-cable shorting for thermo-set cables is considered to be substantially less likely than intra-cable shorting. Hence, the inspection of potential spurious operation issues involving inter-cable shorting for thermo-set cables is being deferred pending additional research.'
The circuits affected are ungrounded 125 VDC circuits. A single fire-induced cable-to-cable hot short will not result in spurious opening of the PORVs. In order to open a single PORV, a minimum of two conductor-to- conductor shorts of the proper polarity would be required. NEI 00-01, dated May, 2003, Appendix B-1 provides a justification for eliminating this type of hot short from consideration (for cases other than high/low pressure interfaces) because of the extremely low likelihood of occurrence. This would be unlikely in the described case because the energized conductors are in separate cables from the deenergized conductors. Therefore the cables would be separated by cable jackets in addition to the conductor insulation within the raceway making a hot short less probable than a conductor to conductor short in the same cable. NEI 00-01 reports the results of EPRI TR-1003326, Characterization of Fire-induced Circuit Failures: Results of Cable Fire Testing. One area discussed by this report is the potential duration of spurious operation events.
The test data used for the EPRI report shows that a majority of the circuit failures resulting in spurious operation had a duration of less than 1 minute. Less than 10% of all failures lasted more than 5 minutes, with the longest duration recorded for the tests equal to 10 minutes. From this it may be concluded that the chance of having two such faults at the same time on the specific conductors to cause a spurious actuation would be extremely unlikely.
Fire testing indicates that spurious actuations do not typically occur for 30 minutes or more, especially for thermoset cable, allowing for additional operator action time, and time to detect and extinguish the fire before spurious actuations occur.
The probability of needing the PORVS to remain isolated during a fire in the postulated areas is 100 percent of the time. Since the total fire initiating event frequency for all of the postulated areas are modeled in the current BVPS Unit 2 PRA is 2.1 OE-03 per year, the probability of needing this safety Page 6 of 8
JUL-Wt-eWU41 NM-. =HVtM VHLLtY H.
I, 1Yt CORRECTIVE ACTION CR Number; NOP-LP-2001-05 03-08460 function is then 2.1 8E-03.
However, if a hot short occurs that causes an unisolated PORV LOCA (i.e., causes the PORV to open and prevents the associated PORV block valve to close) the resultant scenario is similar to a non-isolable small break LOCA. The probability of a multiple hot short is assumed to be 0.01 (0.1 0.1) based on NEI 00-01, Rev. 0, Table 4-2 for Medium probability of occurrence (separate multi-conductor cables), BVPS use of thermoset cables, and the fact that the postulated hot short would involve separate cables. Therefore, the conditional probability of having a non-isolable small break LOCA during one of the postulated fires modeled in the PRA is 0.01 (Split Fraction PRHS), which results in a core damage frequency of 3.99E-06. This results in an increase of 3.3E-07 in the core damage frequency assuming that the manual operator actions (for deenergizing the circuit and/or closing the block valve) and fire brigade response is unsuccessful in preventing the fire induced spurious operation PORV LOCA, which is considered to be of low risk significance A proposed change to the UFSAR Appendix 9.5A has been prepared including a markup of the section on technical justification of deviations from BTP CMEB 9.5-1. See scanned attachment.
Correctiva Action ImplementatIon Date: 10122103 I Signature indicates Corrective Action complete:
Completed By: KARL. H Date: 10/22/2003 2i Signature indicates verification for SCAO CRs:
Verified By: Date:
a Enter Name and Sign:
Implementing Organization Approval: Mancleras. M Data: 10122/2003 U V Comments:
UE A R L I I F T I Y E R Approval: Date:
Page 7 of e
JUL-06-2004 15:52 NRC BEAVER VALLEY P. 18 CORRECTIVE ACTION CR Number:
NOP-LP-2001-05 03-08460 CR Category: Action Type: Schedule Type: CA Number:
CF (V) Other (F) Date or Milestone Relatod/Long Range 6 Corrective Action Type: Cause Code: Resp Org:
O (OT) Other Actlon (NA) Not a Deficiency 0065 R Description!
I BCO 2-03-003 Rev. 1, approved 9/24/03, will remain in effect until resolution of the issue. A G proposed 'deviation request" to Branch Technical Position CMEB 9.5-1 'has been submitted to NhRC I (Ref. CA 03-08460-04) for their review/approval by the NRC before the BCO can be removed.
N A NRC FP Triennial Inspection Report 2004-02 dated March 2, 2004 for BVPS Unit 2 identified this T issue as an Unresolved Item (URI 05000412/2004002-01), potential for spurious opening of the O PORVs due to multiple cable-to-cable hot shorts caused by lire damage. Closure of this item will R depend on the review/approval by the NRC of the proposed "deviation request" submitted by BVPS (L-04-019 dated 2/13/04).
This CA will track the closure by Reg Affairs of this issue (NRC's URI and the BCO), which is dependent on the NRC review/approval of the deviation request.
Completed By. Organization: Date: Phone; Attachments:
MARACEK. J 0060 3/52004 5232 l Yes E 14o If a Pefuellng Outage Is required. Other Tracking # Corrective Action Due Date:
ACC- Enter the Refueling Outage number: N/A 4/26/05 EPT Approval: (Enter Name and Sign) Section: Date:
MARACEK. J 0060 3/5/2004 OUAL Ouality Organization Approval: Dato:
-ITY
Response
P ML E
M N
T Corrective Action Implementation Date:
N ;. Signature Indicates Corrective Action complete:
G Completed By: Date:
1 Signature Indicates verification for SCAQ CRs:
O Verified By: Date:
R ,j Enter Name and Sign:
Implementing Organization Approval: Date:
a V Comments:
U E A R L I I F T I Y E R Approval: Date:
Page of 8
JUL-06-2004 15:52 NRC BEAVER VALLEY P.l19 INVESTIGATION
SUMMARY
CR Number:.
03-OB460 NOP-LP-2001-06 Category I Eval: CF Assigned Organization: 0030 Quality Followup Req'd: O Yes E1 No
'For Fix lnvestigations On~ly;:. 3 .:. -* . *.5'
'.1 HrordswaroDegradad Conrdilion Resolution RequIred7 Ye N _,Sctap, 2 , .Rr
.j~Rewo$~ UO.sl n Acceptance of the CR Investlgailon signifIes acceptance of the following Htms, as Epp icable:
OrIgInator Idontification Date Corrective Actions ( listed below) (listed below, if any) (listed bolow, If any)
Cause Analysis Generic Implicatlons KAllL H 10 CFR 21 Decision Checklist Acceptance of Investigation: Date: Ouslity Approval: Date:
Manoleras, M for Manoloras 9/1d/2003 Slte-VP Acceptance: Date:
Closure Comments:
none Quality Comments:
CORRECTIVE ACTIONS Resp CA Sched CA Cause Org. Accept Due Completed Number: Type: Type: Code: Codes: CA Acceptance: Date: Date: Date:
2 1
A A
j NA NA B04 0030 0062 0030 0 3 ROLLOVER.
' SEPELAK, B MANOLEAAS .M 4 i
/1103 9i2t03 915103 81103 10/i5/04 8125/03 9/1e/03 9/24i03 i . A CM NA 6665 .MARACEKJ 9/12/i3 2Vi4io0 2/1 304 5 A CM H03 0030 LUBEFT. R 9111103 10122/03 10/22/03 6 . F OT NA 0065 MARACEKiJj 3/5104 4/26/05 Page 1 of I
1: b NRC SERVER VALLEY JJULbUkI4 UL-Ub-UW4 lb): NRC BEAVER VALLEY P.20 NOP-LP-2001-09 Corrective Action Due Date Extension CR #: 03-08460 CA #: 4 Requested Due Date: 12/12103 Extension Number: 1 Category: CF Reason for Extension:
NRC Information supplied via Federal Register Vol 68. No. 159 (page 49532) on August 18 2003 regarding hot shorts was sent out for industry comments and will be officially Issued as an RIS (Regultory Issue Summary) In November per the NRC schedule. Therefore, before the deviation request can be submitted to NRC. the RIS would have to have been issued to the Industry for use. Discussions with NRC have Indicated that this would be the proper order before a deviation request should be submitted to NRC for revIow/approval.
Justification:
Reg Affairs Wil provide the deviation request submittal to NRC, upon issuance of the RIS by the NRC for industry use, scheduled for end of November 2003.
Requestor: MARACEK, J Requestor Date: 10/29/03 Approver: Maracek, J for Freeland l IApprover Date: 10/29/03 li Accept O Roject Thursday, March 11, 2004
JUL-05-2004 15:52R NRC BEAVER VALLEY P. 21 NOP-LP-2001-09 Corrective Action Due Date Extension CR #: 03-08460 CA #: 4 Requested Due Date: 2114/04 Extension Number: 2 Category: CF Reason for Extension:
NRC Informaion supplied via Federal RegisterVol 68, No. 159 (page 49532) on August 16. 2003 regarding hot shorts was sent out for industry comments and will be officially issued as en RIS (Regultory Issue Summary).
Before the deviation request can be submitted to NRC, the RIS must be issued to the industry for use. Discussions with NRC have indicated that this would be the proper order before a deviation request should be submitted to NRC for reviewlapproval.
The NRC schedule for issuing the FIS was changed from November to late December 2003/ early January 2004.
Justification:
RFg Affairs will provide the deviation request submittal to NRC. following issuance of the RIS by the NRC for industry use.
The FUS is scheduled to be Issued in December 2003/ early January 2004.
Rcquestor: MCMULLEN, K Requestor Date: 12/11/03 Approver: Maracek. J for Freeland Approver Date: 12111/03 E Accept E Reject Thursday, March 11, 2004
JtUL-Ut:dYU4 1 DK; Z rqmt- ZtlHVCK VHLLtY r. _-
I_
NOP.LP-2001-09 Corrective Action Due Date Extension CR #: 03-08460 CA#: 5 Requested Due Date: 10122103 Extension Number: 1 Category: CF Reason for Extension, Recent emergent work activitles and 2R10 support have prevented completion of this assignment JustificatIon:
The subject matter of this corrective action is lor engineering to provide a technical bases for a deviation submittal to the NRC from the current Unit 2 license regarding fire Induced spurious actuation of the POAVs circuitry.
UFSAR Section G.SA.1.2.1.6, Connecton to Control Circuits/Spurious Operation, states that The safe shutdown capability should not be adversely affected by a fire In any plant area which results it spurious actuation of the redundant valves In any one high-low pressure interface line.'
Justification:
ECO 2-03-003, Rev 1 provides the technical justinfeation for continued operation and has implemented shlftly fire watches as compensatory measures ior the affected areas.
Requestor: DEVINE, J Requestor Date: 10/17/03 Approver: Sockaci, Tfor Manoleras Approver Date: 10/17/03 f Accept O Reject Thursday. March 11. 2004 TOTAL P.22